HolboxAI – Anti-Corruption, Business Ethics, and Compliance Policy
This policy codifies the principles that govern our conduct in all jurisdictions where we operate, maintaining a zero-tolerance approach to bribery, corruption, fraud, or any conduct that compromises integrity.
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1. Purpose and Commitment
HolboxAI ("the Company") recognizes that ethical conduct is the foundation of sustainable growth and long-term trust. This Anti-Corruption, Business Ethics, and Compliance Policy (the "Policy") has been adopted to codify the principles that govern our conduct in all jurisdictions where we operate.
The Company maintains a zero-tolerance approach to bribery, corruption, fraud, or any conduct that compromises integrity. All directors, officers, employees, agents, contractors, and business partners of HolboxAI are bound by this Policy and are expected to comply both with its express provisions and with its spirit of integrity and accountability.
2. Scope of Application
This Policy applies to all individuals employed by or engaged with HolboxAI, including permanent, temporary, and contract staff, as well as consultants, intermediaries, resellers, joint venture partners, and other third parties acting on the Company's behalf.
The obligations herein extend to interactions with private businesses, public institutions, and government officials, regardless of whether the conduct occurs within or outside of the United States. No cultural custom, business norm, or local practice shall justify a deviation from this Policy.
3. Definitions
For the purposes of this Policy, the following terms shall have the meanings assigned to them, it being expressly understood that such definitions shall apply broadly and inclusively, and shall cover all direct and indirect acts, whether undertaken personally, through intermediaries, or otherwise:
"Bribery"
Shall mean the act of directly or indirectly offering, promising, giving, requesting, soliciting, or accepting any financial or non-financial advantage, benefit, reward, or inducement, of whatever nature or value, whether tangible or intangible, in order to improperly influence the judgment, decision, action, or inaction of any person in a position of trust, whether in the public or private sector. Bribery shall include, but not be limited to, securing business, obtaining an improper business advantage, retaining business, influencing official acts, or causing another to act dishonestly or improperly in the discharge of their duties.
"Government Official"
Shall include any elected or appointed official, officer, employee, or representative of any national, state, provincial, municipal, or local government, agency, authority, or instrumentality thereof; any individual acting in an official capacity on behalf of a government entity, department, or regulatory body; any political party, party official, or candidate for public office; any officer or employee of a government-owned or government-controlled enterprise; and any officer, employee, or representative of a public international organization, including but not limited to the United Nations, World Bank, International Monetary Fund, or similar multilateral or supranational bodies.
"Facilitation Payment"
Shall mean any payment, however nominal in value, made to secure, expedite, or facilitate the performance of routine, non-discretionary governmental actions or administrative services to which the payer is already legally entitled, including but not limited to actions such as processing permits, licenses, visas, customs clearances, police protection, mail or utility services, or loading and unloading of cargo. For clarity, such payments, regardless of their size, frequency, or customary acceptance in a local jurisdiction, are strictly prohibited by this Policy and shall constitute an act of bribery.
"Gift"
Shall mean any item, service, benefit, privilege, favor, advantage, or thing of value, whether tangible or intangible, provided without an expectation of fair market consideration, and shall include, without limitation: cash, cash equivalents, loans, discounts, rebates, vouchers, merchandise, artwork, jewelry, personal property, services, employment opportunities, preferential treatment, tickets to events, transportation, travel, lodging, meals, entertainment, hospitality, sponsorships, charitable donations made at the request of another, or any other benefit conferred upon a person.
"Third Party"
Shall mean any natural person or legal entity, not being the Company or its direct employees, that is engaged, retained, or otherwise authorized to act on behalf of, represent, assist, support, or provide services to the Company in any capacity. This shall include, without limitation, consultants, advisors, agents, contractors, subcontractors, suppliers, vendors, distributors, resellers, joint venture partners, intermediaries, and any of their affiliates, representatives, or employees.
4. Compliance with Laws
HolboxAI conducts business in accordance with all applicable anti-corruption, anti-bribery, and compliance statutes, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act (where applicable), and relevant state and federal laws. All employees and representatives are expected to know, understand, and comply with these laws. Ignorance of the law or this Policy shall not constitute a defense.
5. Prohibition of Bribery and Improper Advantages
No person acting on behalf of HolboxAI shall, directly or indirectly, offer, authorize, solicit, or accept any form of payment, gift, entertainment, or advantage with the intent or effect of improperly influencing a decision, obtaining business, or securing an undue advantage. Facilitation payments are strictly prohibited under all circumstances. Even where no improper intent exists, employees must avoid situations that could create the appearance of impropriety or undermine trust.
6. Gifts, Hospitality, and Entertainment
The exchange of modest business courtesies is permissible only if they are customary, lawful, transparent, and of nominal value. Such courtesies must not, in any way, create a sense of obligation or expectation of reciprocity. Cash gifts or equivalents, such as vouchers, pre-paid cards, or securities, are strictly prohibited.
Employees must exercise heightened caution in dealings with Government Officials: no hospitality, travel, or entertainment may be extended without prior written approval from the Compliance Officer, and only where permitted by law.
7. Commissions, Fees, and Third-Party Engagements
All arrangements with third parties must be governed by written contracts that detail the nature of services, compensation, and terms of engagement. Payments must be reasonable, commensurate with legitimate services rendered, and recorded accurately in the Company's books. HolboxAI expressly prohibits the use of intermediaries to disguise bribes or to channel improper payments. Third parties who fail to adhere to this Policy shall be subject to termination of relationship and possible legal recourse.
8. Ethical Conduct and Business Integrity
Employees and representatives of HolboxAI must act honestly, fairly, and with the utmost professionalism in all business dealings. Confidential information belonging to clients, employees, or the Company must be protected at all times. Actual or potential conflicts of interest must be disclosed immediately. The falsification, manipulation, or concealment of records or accounts is prohibited and will be treated as gross misconduct, exposing the violator to disciplinary action and potential criminal liability.
9. Record-Keeping and Documentation
The Company requires accurate and transparent record-keeping to ensure compliance with legal and ethical obligations. All accounts, invoices, expense claims, and documentation must be complete, truthful, and properly recorded. No false, misleading, or artificial entries shall be made in the Company's books. All supporting documents relating to business transactions must be retained in accordance with legal and regulatory requirements.
10. Reporting and Whistleblower Protection
Employees and associated persons are obligated to report any suspected or actual breach of this Policy promptly to the Compliance Officer through designated reporting channels. Reports may be made confidentially and will be investigated promptly and thoroughly. HolboxAI strictly prohibits retaliation against any individual who raises concerns in good faith. Retaliation itself shall be treated as a violation of this Policy.
11. Training and Awareness
HolboxAI shall provide regular training on anti-corruption and business ethics to employees, managers, and relevant third parties. Participation in such training is mandatory. Employees are expected to remain informed of changes in applicable laws and Company policies.
12. Disciplinary Action and Legal Consequences
Violations of this Policy shall result in disciplinary action, which may include reprimand, suspension, demotion, termination of employment or contract, and restitution. Where the violation constitutes a breach of law, the Company will fully cooperate with authorities and violators may face prosecution, fines, or imprisonment.
13. Waivers and Exceptions
No waiver, exemption, or deviation from this Policy shall be valid unless approved in writing by the Compliance Officer and, where necessary, ratified by the Board of Directors. Requests for exceptions shall be considered on a case-by-case basis, and only where the waiver does not compromise the Company's legal or ethical obligations.
14. Governance and Periodic Review
This Policy has been adopted by the Board of Directors of HolboxAI and shall form part of the Company's corporate governance framework. The Policy will be reviewed annually, or more frequently if required by changes in law, regulatory guidance, or business operations. Updates shall be communicated to all employees and stakeholders, and compliance with the revised Policy shall be mandatory.
15. Jurisdiction and Governing Law
This Policy shall be governed by and construed in accordance with the laws of the United States and the State of Wyoming, without regard to conflict of law principles. Any disputes or claims arising under this Policy shall be subject to the exclusive jurisdiction of competent courts in the State of Wyoming, unless otherwise required by law.
16. Contact and Oversight
Questions concerning this Policy, requests for clarification, or reports of violations may be directed to:
Email: admin@holbox.ai
HolboxAI considers adherence to this Policy to be a condition of employment, partnership, and association. By following these provisions, the Company ensures that its business is conducted with honesty, fairness, and transparency, safeguarding its reputation and strengthening its role as a trusted leader in the AI and software industry.